1. Introduction

Farewell Fund ("Farewell Fund", "we", "our", or "us") respects your privacy. This policy explains what personal information we collect through our website, why we collect it, how it's used and protected, and the rights you have over it. It's written to comply with South Africa's Protection of Personal Information Act 4 of 2013 ("POPIA"), which governs how organisations in South Africa ("responsible parties") may lawfully process personal information.

This policy should be read together with our Terms and Conditions.

2. Information We Collect

Depending on how you use Farewell Fund, we may collect:

  • Account information: name, email address, and phone number when you sign up.
  • Campaign content: text, photos, and other details you add to a fundraiser.
  • Verification documents: identity documents, a death certificate, a funeral quotation or invoice, and proof of your relationship to the deceased, submitted when we verify a campaign.
  • Banking information: the account details needed to pay out verified funds.
  • Donation information: the amount and timing of donations, and whether a donor chose to give anonymously. Card and payment details are handled directly by our payment processor. See Section 6.
  • Communications: messages you send us, for example through our contact form.

3. How We Use Your Information

We use personal information to:

  • Create and manage your account.
  • Verify fundraisers, as described in our Terms and Conditions.
  • Process donations and release payouts to verified beneficiaries.
  • Detect, investigate, and prevent fraud.
  • Respond to support requests and other communications.
  • Meet our legal and regulatory obligations.

We do not sell personal information, and we do not use it for unrelated marketing without your consent.

4. Our Lawful Basis for Processing

POPIA requires that personal information only be processed where there is a lawful basis for doing so. We rely on one or more of the following, depending on the situation:

  • Your consent: for example, when you create an account or submit a campaign.
  • Performance of a contract: to provide the fundraising and donation services you've asked for.
  • Compliance with a legal obligation: for example, fraud reporting or record-keeping requirements.
  • Our legitimate interests, such as keeping the platform safe and preventing fraud, balanced against your rights.

5. Special Personal Information

Some verification documents, such as a death certificate, may contain special personal information under POPIA (for example, health-related information about the deceased). We only collect this where necessary to verify a genuine funeral-related campaign, we limit access to it internally, and we do not use it for any purpose beyond verification, fraud prevention, and legal compliance.

6. Sharing Your Information

We share personal information only where necessary, with:

  • Our payment processor: to process donations and payouts securely.
  • Verification support: where a third party assists us in confirming the authenticity of documents you submit.
  • Law enforcement or regulators: where required by law, or in connection with suspected fraud.
  • Professional advisors: such as legal or accounting advisors, bound by confidentiality.

We do not share verification documents, banking details, or donation records with other users or the public.

7. Cross-Border Transfers

We aim to use South African-based service providers wherever practical. If any information is processed or stored outside South Africa (for example, by a hosting or infrastructure provider), we take reasonable steps to ensure it receives a level of protection consistent with POPIA before any such transfer takes place.

8. Data Retention

We keep personal information only for as long as it's needed for the purposes described in this policy, including the time needed to meet legal, accounting, or fraud-prevention requirements, and delete or de-identify it once it's no longer required.

9. Security

We use reasonable technical and organisational measures to protect personal information against loss, unauthorised access, alteration, or disclosure, including restricting access to verification documents and banking details to those who need it to do their job. No online system is completely secure, so we can't guarantee absolute security, but we work to keep these safeguards current.

10. Your Rights

Under POPIA, you have the right to:

  • Ask us to confirm what personal information we hold about you, and to access it.
  • Ask us to correct or update inaccurate or outdated information.
  • Ask us to delete personal information we no longer have a lawful basis to keep.
  • Object to the processing of your personal information in certain circumstances.
  • Withdraw consent you previously gave us, where processing is based on consent.

To exercise any of these rights, contact us using the details in Section 15. We may need to verify your identity before acting on a request.

11. Children's Privacy

Farewell Fund is only for use by people aged 18 and over, as set out in our Terms and Conditions. We do not knowingly collect personal information from children.

12. Cookies and Tracking

At this stage, the Farewell Fund website does not use analytics, advertising, or tracking cookies, only what's strictly necessary to keep the site and your session working. If we introduce analytics or marketing tools before launch, this section will be updated first to describe what's used and the choices available to you.

13. Complaints

If you're unhappy with how we've handled your personal information, please contact us first so we can try to resolve it. See Section 15. You also have the right to lodge a complaint with South Africa's Information Regulator, the body responsible for enforcing POPIA, at inforegulator.org.za.

14. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or the law. Updated versions will be published on this page, and the effective date at the top will change accordingly.

15. Contact Us

Questions about this Privacy Policy, or requests relating to your personal information, can be sent to support@farewellfund.co.za, or via our contact page.